Note This law applies to U.S. customers only. Customers should rely on appropriate legal counsel and outside auditors for interpretation of the act’s requirements. Suggestions in this document are not to be construed as a substitute for legal advice or a definitive list of all possible legal considerations.
In 2005 the U.S. Federal Communications Commission issued the order, IP-Enabled Services and E911 Requirements for IP-Enabled Service Providers, First Report and Order and Notice of Proposed Rulemaking. The order required providers of interconnected voice over Internet Protocol (VoIP) service to supply enhanced 911 (E911) capabilities to their customers. However, these acts currently apply only to telephone and IP telephony service providers and not to enterprise telephony users. Therefore, the E911 Act does not currently apply to Messaging.
However, the Occupational Safety and Health Administration (OSHA) might consider failure to implement E-911 as a direct violation of Section 5(a)(1) of the Occupational Safety and Health Act, also known as the General Duty Clause, which requires employers to furnish a workplace which is free from recognized hazards, which may cause, or are likely to cause, death or serious physical harm.
In addition, there are roughly 17 states with current or pending legislation requiring enterprise switches to be able to dial 911 and report the caller's number, associated with a physical location. The customer must check with the regulations of the customer’s state to clarify what state requirements might exist regarding 911 calling for enterprises providing telephone systems for employees.